Caguioa Doctrinal Case Digest: Spouses Tapayan v. Martinez

(G.R. No. 207786. January 30, 2017)

Civil Law: Presumption of Regularity

Whether the petitioners Tapayan presented clear and convincing evidence of fraud to refute the presumption of regularity ascribed to the Deed of Undertaking?

No. Like the Deed of Undertaking in the instant case, a public document acknowledged before a notary public enjoys the presumption of regularity. Petitioners failed to provide clear and convincing evidence supporting their claim that their signatures were forged to overthrow the presumption of regularity given to notarized documents

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